Chapter 333: Six Pages of Complaint

January 23, 9 a.m. The radiator had just warmed up, and the room still held the night's chill. Downstairs, oil sizzled in a wok, and the smell of scallions climbed the stairwell, spreading out against the condensation on the window glass.

Shen Zhixia spread a stack of blank manuscript paper across the long table. She had cut the sheets from the firm's old paper stock; the edges were rough from the paper cutter. One by one, she pressed each rough edge flat.

"We don't start from page one," she said.

"Where do we start?" Lu Jibai looked up from the desk by the door.

"From the claims. If the claims don't hold up, the body can be written beautifully and it won't matter."

Li Huilan sat in the chair beneath the window, the arbitration award from Lao Kan's case spread across her lap. She didn't look up. "Starting with the claims is right. The judge turns to page one and first looks at what you're asking for."

Shen Zhixia pulled out a sheet of paper, wrote "Claims for Relief" at the top, left the space below blank, and wrote from top to bottom.

1. Order the defendant to immediately cease discharging lead-containing wastewater from the stormwater outlet of the East Hill plant area through the drainage ditch to the foothills below, and prohibit further discharge until the outlet passes rectification and acceptance inspection.

2. Order the defendant to eliminate the danger by removing pollutants deposited in the ditch bed, the farmland along the ditch, and the soil of the village primary school playground.

3. Order the defendant to restore the damaged ecological environment; if restoration is not completed within the time limit or fails to meet standards, order the defendant to bear the costs of ecological environment restoration.

4. Order the defendant to compensate for loss of ecological environment service functions from September 2025 until restoration is completed.

5. Order the defendant to bear the reasonable litigation expenses of this case, including appraisal fees, inspection fees, and notarization fees.

6. Order the defendant to issue a public apology in Jiangzhou Daily.

She wrote one, then read it aloud. When she reached the fourth, Li Huilan closed the arbitration award and turned halfway around from her chair.

"For the fourth claim's starting date—what day do we write?"

"September 2025," Shen Zhixia said. "That round of external discharge tested over the lead limit. It's on the public notice."

"The notice says it was discovered during inspection," Lu Jibai said. "It doesn't say when the discharge began. Put a date on it, and they'll answer, 'That day we hadn't discharged anything yet,' and the whole claim just hangs there."

She stopped the pen on the paper.

"Then what do we write?"

"Write 'from the date the external discharge from the defendant's stormwater outlet exceeded the lead standard.' Let the appraisal determine the date. We don't have that paper in hand, so we don't speak for it."

She crossed out the line and rewrote it. One horizontal stroke—she didn't black it out.

"Claims one and two—aren't they redundant?" Li Huilan asked.

"One is water, two is land," Lu Jibai said. "Write both. The court may recognize only one, or it may rule on both together; leave one out, and whatever's decided leaves that part with nowhere to land."

"Should we even include the cessation claim?" Shen Zhixia asked. "They were fined once back in September of the year before last. They'll claim it's already been rectified, that they stopped long ago."

"We include it."

"If they respond that it's already stopped, there's nothing left to rule on."

"Better that a judgment can't be enforced than to have no such line on paper." He said. "Leave it out, and if they discharge again this year, you won't even have a claim to make."

For the fifth claim, she had originally written "attorneys' fees." He reached over and crossed out that item, writing beside it: public-interest representation, no agency fees charged.

"We can't write that claim."

"I wasn't planning to take any money."

"It's not about the money." He set down his pen. "Write that claim, and opposing counsel's first words in court will be: the plaintiff claims not to profit, so why is she paying herself a salary? We waive the fee, and he can't get a word in."

For the sixth, she had written "publish a public apology in Jiangzhou Daily." He read it and crossed out the newspaper name.

"Write 'media at or above the provincial level'; let the judgment decide which outlet. Name one specific paper, and if that paper refuses to run it, the judge can only dismiss the claim."

She turned the page back and read through each claim. Six claims, six lines, evenly spaced.

[Thud. Six claims. Not one extra, not one missing.]

At 10:40, she wrote "Facts and Reasons" at the top of another page.

The first sentence came easily: Nine years ago, this water came down the mountain through Baixi Village, and the villagers first learned it could not be drunk.

It felt right, so she kept going for two more lines. On the third line, when she reached "that case," a hand reached over from her right. A pencil tip touched the paper.

The pencil was sharpened to a fine point. It drew one stroke, light, the words still legible beneath. Starting from "Nine years ago," it crossed through to the period.

"What's wrong with this sentence?" she asked.

"Everything." Lu Jibai said. "The moment these words appear, their first question will be: what's your source."

"I have a source."

"What you have belongs to that other case. Not this one. In this case, the water only comes down from a map."

She gripped the pen for a moment, then crossed out the entire line and began a new paragraph.

The defendant's plant is located on East Hill, Baixi Village, in the Chengxi area of Jiangzhou City. The external discharge from the plant's stormwater outlet runs down the mountain, passes through Baixi Village, reaches the entrance of Qingshi Village, passes through the culvert beneath the highway, and flows east along the road base.

After she wrote this sentence, he said beside her: "One sentence, one number."

"What number?"

"The evidence list number. Which sheet of paper does this sentence point to?"

She flipped out the draft evidence list and began numbering from one: corporate public record, pollution discharge permit information, administrative penalty public notice, environmental assessment approval, public map screenshot, two photocopies of lab test reports, diagnosis certificate, the Consent Form. Beside the environmental assessment approval she wrote "to be supplemented"—the notarial certificate wasn't out yet.

She wrote the numbers at the end of each sentence in pencil, small. When she reached the sentence about "farmland along the ditch," the pen tip stopped.

"I've never been to that land."

"Places you haven't been still exist on paper." He pushed the map screenshot toward her. "The ditch is drawn on this map, and so is the land along it. Write 'as shown on the map,' not 'I saw.'"

She revised accordingly. After revising, she read it aloud. It sounded thin to her own ear—thin, and that was right. Not one word extra.

For the fourth paragraph, she wrote: Six children in the village tested above the reference range for blood lead.

"Which sheet does this sentence point to?"

"Only one of the six families' lab reports is in our hands," she said. "The other five didn't provide theirs."

"Then write one." He said. "Six children—we know that in our heads. The paper doesn't."

She crossed it out and rewrote: The lab test report provided by the plaintiff shows that one child's blood lead test result exceeded the reference range, and a medical institution diagnosed the child with lead poisoning (mild).

Beside the reference number she added a small note: only one report in the materials, not six.

This sentence was exactly what the procuratorate officer had said in person on the 22nd. She copied it down without changing a single word.

When she reached "the villagers dare not sue," she paused herself.

"What about this sentence?"

"Cross it out." He said.

"It's true."

"Truth also needs a source. The source is one spoken sentence, from someone who won't put their name to it. Put it in, and when they ask who said it, you can't answer."

She crossed out the sentence and wrote in the margin for herself: Villagers dare not speak — don't submit.

"These words don't go into the paper," Li Huilan said from beneath the window. "They go into our own notebook. The day someone is willing to put their name to it, we copy it from the notebook into the paper."

In the afternoon, she combined the six claims with the body text, adjusted the font and line spacing, and paginated at the bottom. After finishing the last line, she counted the pages once through, then counted back from page one. Six pages.

Three applications followed the six pages. The appraisal application had five items: the type and nature of the pollutants, the source of the pollution, the scope and extent of the damage, the restoration plan and costs, and interim loss of ecosystem service functions. For the evidence preservation application, she wrote: ditch water, ditch bed sediment, farmland soil along the ditch, and village primary school playground soil are susceptible to rainwater erosion and human disturbance; request sampling, testing, and preservation. The fee deferral application stated only that the plaintiff is a social service institution engaged in no profit-making activity, with sources and amounts of funding attached.

By the time she finished these, it was dark outside. She clipped the six pages into the case file and weighed them down with a paperweight.

"This document," Li Huilan asked as she put on her coat, "who's going to read it to Chai Guizhi?"

"Nobody in the village can see the paper we file," Lu Jibai said.

"She needs to know the gist." Shen Zhixia said. "I'll call her tonight and go through it item by item. I won't read the words—I'll read the meaning."

January 24, 9 p.m. At the desk in her apartment, she finished reading the last page of Volume Three.

The desk lamp was tilted slightly left; she straightened the shade. Nine volumes sat stacked at the corner of the desk, the first few facing outward. The spines of the bottom three were pressed out of sight—she didn't move them.

The last item in Volume Three was a visit form with hand-drawn grid lines: seventeen names, a number after each. Some names were half-written, corrected, supplemented beside them. One grid was empty—cleanly empty, not an oversight.

A line of small writing in the margin: Ask him—can he hear the child calling him.

She sat motionless below that line for a while.

Volume Three's case wasn't complicated: a small stamping-parts factory in Chengdong had withheld seventeen workers' wages for two years; the workers pooled their money to hire him. The margins contained not statutes but "three questions to ask"—how many days did you work this month, which days didn't you work; who kept your count. The middle question had been crossed out and rewritten twice.

Elsewhere in the margin: Don't ask if she understands. Ask if she recognizes this character.

She remembered a morning on January 11, reading an Agreement clause by clause to an illiterate elderly woman, pausing after each clause to ask, "What does this sentence say?" She had assumed back then that Li Huilan had taught her the method.

She pulled the index page out from behind the first volume's title page. Four columns. In the third row, "what case is in here" was still blank, the small dot where a pen tip had once pressed still visible.

She picked up her pen and wrote in that box: Chengdong stamping-parts factory, seventeen people's wages; one man's hearing.

The box was narrow, the characters cramped, spilling past the line. She didn't rewrite. She added a small note beside it: see margin of Volume Three.

When she finished, she held the page up to the light. Three of nine rows were filled. The last column still gaped hollow.

Lu Jibai's message came in at 9:50: Finished Volume Three?

Finished.

Did you fill in the case column?

Filled it.

He paused before replying: Did he write it, or did you.

She replied: I wrote it.

Good. Sleep early. Read through the six pages again tomorrow.

January 25, 10 a.m. A stiff paper envelope arrived at the firm. Mailed from Guangdong, corners creased and flattened, addressed to the firm's name in handwriting that slanted upward.

She opened it. Inside, a one-page Consent Form, folded twice, the creases pressed deep. The signature ran past its box; the date field read the 21st.

She verified it: who signed, which pages it covered, what the purpose line said. After checking, she handed it to Lu Jibai.

He placed the original into a kraft paper envelope and added a line on the front: Ge Changlin signed in Guangdong on January 21, mailed the 22nd, arrived at the firm the 25th. After writing it, he read it aloud, pausing at "arrived at the firm," and asked her, "This journey—logged?"

"Logged."

5 p.m., Qinghe Center, third floor.

Cai Qingru spread a notarial certificate across the long table. A sealed USB drive bag sat pinning down one corner. She had picked it up from the notary office that morning; the signed receipt was still tucked in her bag.

"Four pages," she said. "We check page by page."

Attached behind the notarial certificate were four printed pages: the corporate public record, the pollution discharge permit, the administrative penalty notice, the environmental assessment approval. At the bottom of each page was a line noting the access time and URL; the final page bore the notary office's seal.

Shen Zhixia slid the last page closer and compared it line by line against the complaint.

At the corporate public record page, she stopped.

She had written "business scope includes battery cathode materials." The printed page read "battery cathode materials (excluding hazardous chemicals)."

"This one doesn't match," she said.

"Which side do we change?" Cai Qingru asked.

"Our side." Shen Zhixia pulled the complaint over and added the parenthetical. "The paper says it that way, so we write it that way. One word more or less, and it'll fall apart the moment someone checks."

After the correction, Cai Qingru began flipping through the six pages from the first. At page five, she looked up.

"The apology claim—why provincial level or above?"

"Name one specific outlet and if it refuses to publish, the judge can only dismiss. Write 'provincial level or above,' and the judgment picks one. It lands."

"Why only one child?"

"Only one lab report signed by a parent. The other five families didn't give theirs. Put six into the complaint and when they ask for the source, that whole section collapses—and it drags this one report down with it."

"Cessation of discharge and elimination of danger—they look like the same thing."

"One is water, one is land. Leave one out, and whatever's decided has nowhere to land."

Cai Qingru stopped asking questions and turned to the last page.

She took a flat iron box from her bag and opened it. The company seal lay inside. The ink pad box sat beside it, lid off, its red dark as dried blood.

"The signature line—I'll write my name," she said. "The seal goes over the name. Press it clean, so the perforation doesn't give away it was added later."

She signed. Her name came out square and upright. Then she lifted the seal from the iron box, pressed it into the ink pad twice, and raised it to check the clarity of the characters.

The seal didn't come down.

"There's something I need to ask clearly," Cai Qingru said. "When this goes in—who's sitting across from us."

"The defendant is a company. They have to send someone to respond," Shen Zhixia said.

"I'm asking about the lawyer. These six pages—who reads them."

The room went quiet for a moment. A car passed below; the window glass hummed once.

Lu Jibai turned over the page in his hand and glanced at it. He answered, "I don't know yet."

The seal came down. She lifted it only after the red had soaked through.